magnox limited hinkley a site environmental management plan
TRANSCRIPT
Environmental Management Plan 2017/18 – Hinkley Point A Site Page 1
HINA/R/EHSQ/038 Issue 15
Magnox Limited
Hinkley A Site
Environmental Management Plan
2017/2018
Environmental Management Plan 2017/18 – Hinkley Point A Site Page 2 HINA/R/EHSQ/038 Issue 15
Executive Summary
In January 2002 Magnox Electric Ltd (now Magnox Ltd) applied for consent to decommission Hinkley Point A Nuclear Power Station under the Nuclear Reactors (Environmental Impact Assessment for Decommissioning) Regulations 1999 (as amended).
Consent was granted by the Health and Safety Executive (HSE) (now Office For Nuclear Regulation (ONR)) in July 2003 subject to 6 conditions. In compliance with condition 2, an Environmental Management Plan was prepared to provide information relating to environmental risks and mitigations anticipated and arising during the project.
This document is the fifteenth issue of the Hinkley Point A Environmental Management Plan which has been updated annually in compliance with condition 5 of the consent. This document provides detail of the mitigation measures available to Hinkley Point A to prevent, reduce, and where possible offset any significant adverse environmental effects of the decommissioning work, and provides an update on how these measures have and will been implemented on site during decommissioning activities carried out in 2017/18.
Peter Montague Closure Director Hinkley Point A October 2017
Environmental Management Plan 2017/18 – Hinkley Point A Site Page 3
HINA/R/EHSQ/038 Issue 15
Contents
1. Introduction 4
2. Scope of the Environmental Management Plan 5
3. The Site and Surrounding Area 6
4. Mitigation Measures 7
5. Implementation of the Environmental Management Plan 16
6. Changes to the Environmental Management Plan 18
7. Distribution of the Environmental Management Plan 18
8. Definitions 18
Appendix A. Consent Conditions 19
Appendix B. Stakeholder Engagement 21
Appendix C. Format of Decommissioning Proposal Form (DPAF) 23
Appendix D. Format of Land Quality Assessment Form 24 Published in the United Kingdom by Magnox Limited, Hinkley Point ‘A’ Site, Nr Bridgwater, Somerset, TA5 1YA. All rights reserved. No part of this publication may be: (i) reproduced used, dealt with, possessed or transmitted in any form or by any means, including photocopying and recording, without the written permission of the copyright holder; or (ii) used, dealt with or possessed in any way whatsoever, where such use, dealing with or possession will or may infringe any intellectual property rights of the publisher (including any trade marks, patents or patents pending, design right (registered or unregistered), know how, show how, moral rights or any license held by the publisher with a third party). Application for permission to reproduce, transmit, use, deal with or possess should be addressed to the publisher. Such written permission must also be obtained before any part of this publication is stored in a retrieval system of any nature. Requests for copies of this document should be referred to: Document Centre, Magnox Limited, Hinkley Point ‘A’ Site, Nr Bridgwater, Somerset TA5 1YA. © Magnox Ltd 2017
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1. Introduction
Hinkley Point A Reactor Site (hereafter Hinkley A) ceased
generation in 1999 and was formally shut down in May 2000
after generating electricity since 1965.
The site entered a phase of decommissioning in accordance
with the consent issued by the Health and Safety Executive
(HSE), now the Office for Nuclear Regulation (ONR) in 2003
under the Nuclear Reactors (Environmental Impact
Assessment for Decommissioning) Regulations 1999 (as
amended) (EIADR99).
The consent (Appendix A) details 6 conditions that apply to the
decommissioning project, including a requirement for the
preparation, implementation and review of an Environmental
Management Plan (EMP) that shall describe preferential
mitigation measures to prevent, reduce and where possible
offset any significant adverse effects on the environment. In
addition, the plan shall describe how such measures have
been employed during the various phases of the
decommissioning project including where appropriate the
effectiveness of and changes to such mitigations in the light of
experience giving reasons for such changes.
This issue of the EMP is structured in a way to clearly
demonstrate how Hinkley A meets the requirements of the
conditions of consent as follows:
Condition 3: This document lists the mitigation options
and work activities expected to be required at the
various stages of decommissioning.
Condition 4: This document identifies the mitigation
measures that have been carried out including a
description of effectiveness and any significant
changes.
Other supporting information which may be of interest to
the public but is not directly required by the consent
conditions is also located in the Appendices (e.g.
stakeholder management).
A detailed decision report describing the content of the
conditions attached to the consent and the main reasons
and considerations for the decision was prepared in 2003.
Copies of the document are available from:
Office for Nuclear Regulation
Building 4
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
Tel: 0151 951 4000
email: [email protected]
Or via the internet from:
http://www.onr.org.uk/hinkley.pdf
Any queries relating to decommissioning activities at
Hinkley A or requests for copies of this EMP should be
addressed to:
Closure Director
Hinkley Point A Site
Nr Bridgwater
Somerset
TA5 1YA
Main Entrance - Hinkley Point A
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2. Scope of the Environmental Management Plan
Geographical Scope
The site is situated adjacent to Bridgwater Bay within
the Severn Estuary and is located between a currently
generating nuclear site (Hinkley Point B) and a new
build nuclear site (Hinkley Point C – see picture).
This EMP details the mitigation measures employed on site
to prevent, reduce and, where possible, offset any significant
adverse effects on the environment throughout the
decommissioning of Hinkley A.
Duration
The decommissioning project at Hinkley Point A consists
of a phased approach. These phases are summarised
below: • Care & Maintenance Preparations (C&MP)
During this current phase of decommissioning, most of
the radioactive and non-radioactive plant and buildings
on the site will be dismantled. Intermediate level
radioactive waste (ILW) will be retrieved from current
storage locations as appropriate, processed and then
placed into purpose-built storage. Upon completion of
C&MP, the site will have been put into a passively safe
state where the need for human intervention to maintain
acceptable conditions is minimised, i.e. the Care and
Maintenance period (C&M).
• Care & Maintenance (C&M)
This is a mainly quiescent phase expected to last for
some decades and will require the management,
maintenance and monitoring of the Hinkley A site to
ensure that it remains in a passively safe and secure
state. The site will continue to be the subject of a
Nuclear Site License during this period. • Final Site Clearance
The final phase of decommissioning is expected to last
approximately 10 years and will include the dismantling
of the remaining structures, including the reactor
buildings, the clearance of any residual radioactivity to
the applicable standards at the time and the de-
licensing of the site so that it can be made available for
alternative use, as appropriate.
HPC Site Construction
This EMP is structured around these three phases.
However, it is expected that mitigation measures may
change in the future in light of experience and developing
technologies. Where mitigation measures are still to be
identified, developed in more detail, or require changes,
these will be described in subsequent issues of the EMP
together with reasons for changes made.
The mitigation measures described in the Environmental
Statement have been extracted and tabulated in Section 4.
Topics
The Environmental Statement that accompanied the
application for consent in 2001 described potential
beneficial and adverse environmental impacts of the
Hinkley A decommissioning project.
These impacts were divided into 9 topic areas which have
been used throughout this EMP and are listed below:
Air Quality and Dust
Archaeology and Cultural Heritage
Ecology
Landscape and Visual
Noise and Vibration
Socio-Economic
Surface Water Quality and Draining
Geology, Hydrogeology and Soils
Traffic and Transport
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3. The Site and Surrounding Area
Site Description
Hinkley A is located on the south west coast of England in
the county of Somerset, approximately 13 km North West of
the town of Bridgwater. The Nuclear Licensed Site occupies
an area of approximately 26 hectares and consists of a
number of buildings, hard standings and landscaped areas
(wooded and grassy areas).
View of Hinkley Point A from the Quantock Hills
The two reactor buildings are the dominant features on the
site, each 53 metres high. Each contains a reactor of the
gas cooled, graphite moderated, Magnox type1. The reactor
cores are each contained in a large steel pressure vessel
surrounded by a concrete biological shield. During
operation the reactors were cooled using carbon dioxide.
Boilers converted water to steam in order to drive the
turbines located inside the turbine hall which has now been
de-planted and is awaiting demolition. Cooling of the steam
to return it to water was provided by seawater passed
through condensing units. The cooling water intake and
outfall structures are located offshore and are connected to
the turbine hall by means of large underground tunnels
which are now blanked off.
1
The term ‘Magnox’ refers to the first generation of gas-cooled nuclear reactors used for electricity
generation. It is derived from the cladding material (magnesium non-oxidising alloy) that surrounds
each individual uranium metal fuel element.
Other buildings and plant include the pond buildings,
national grid substation, workshops, stores and offices.
Sensitivity of Receiving Environment
Hinkley A is located adjacent to the foreshore of Bridgwater
Bay, a Site of Special Scientific Interest (SSSI) which is
also designated a National Nature Reserve (NNR). The
wider Severn Estuary is designated a Special Protection
Area (SPA), a wetland of international importance under
the Ramsar Convention and is a Special Area of
Conservation (SAC).
A new Nature Reserve in the Steart Peninsula has been
created by the Environment Agency and the Wildfowl and
Wetlands Trust, approximately 10km from Hinkley A. The
reserve fully opened in May 2015.
A County Wildlife Site (CWS) lies to the west and south of
Hinkley A, within which lies Branland Copse north and
south which are areas of broadleaved semi-natural
woodland. The Quantock Hills lie 7 km south extending to
the coastline at Quantock’s Head and have been
designated as an Area of Outstanding Natural Beauty
(AONB). The Exmoor and Quantock Oak woods are on
the east side of the Quantock Hills and are designated as a
Special Area of Conservation (SAC).
Within a 10 km radius of Hinkley A there are two additional
SSSIs: Ge-mare Farm Fields which lies 7 km south west of
the site and Berrow Dunes which lies near Burnham-on-
Sea to the north east of the site.
There is one site of known archaeological interest at
Hinkley Point, namely an early Bronze Age burial mound or
tumulus dating from around 1500BC. This site is known as
Pixies Mound (Wick Barrow) and is a Scheduled
Monument.
Wick Barrow dating from 1500BC
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Transport Infrastructure
The main vehicular access to Hinkley A, from the M5
motorway to the east, is via the A38 which links with the
motorway north and south of Bridgwater at junctions 23 and
24 respectively. At Bridgwater the A38 joins the A39 and the
route continues west along the A39 to Cannington. From
there the C182 leads north to a private site access road. A
bypass has been constructed to ease congestion in the
village of Cannington and allow easier access to Hinkley
Point.
Extensive upgrade work has taken place in and around
Bridgwater to upgrade the road network to mitigate the
increased traffic that will impact on the area; two examples of
this are shown below:
The works are part of an agreed schedule of improvements
required for the building of Hinkley Point C.
Surrounding villages including Nether Stowey can access
the site from the west via the A39 or via inter-connecting
country lanes which also give access to the C182 either
through Stogursey or Shurton.
There is no direct rail access to the site. The nearest rail
access for passengers and freight is at Bridgwater
involving vehicle movement through the centre of
Bridgwater and the village of Cannington to reach the site.
Bridgwater station is on the main line between Exeter and
Bristol extending to the wider national rail network.
The closest access via water is currently at Combwich
Wharf, which is owned by EdF Energy. There is a cross
company agreement that gives Hinkley A access to the
wharf. HPC have commenced early activities to upgrade
the wharf to support future HPC needs. A jetty is currently
being constructed to allow sea deliveries during the
construction phase of HPC.
HPC Jetty Construction
The area around the site is served well by a network of
public footpaths and bridleways. This includes the coastal
path which runs along the shoreline, to the east of Hinkley
A and B site.
Hinkley Point C
Work is continuing adjacent to Hinkley A site in connection
with the nuclear new build known as Hinkley Point C site.
Current works at Hinkley Point C has seen a steady
increase to the number of vehicles using the site access
road which are not related to decommissioning activities at
Hinkley A.
A new bypass has been constructed to divert construction
and other Hinkley traffic away from the village of
Cannington.
Hinkley A site is supporting preparations for HPC’s
dewatering activities, i.e. the installation of boreholes and
supporting preparations for new electrical supplies to the
HPC site. There are arrangements in place for funding
those activities across the sites. Hinkley A has established
a specific liaison role which is the first point of contact and
enables information passed in either direction to be
directed to the correct personnel.
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4. Mitigation Measures
4.1 Identified Impacts and Mitigation measures
In support of the application to decommission under the Nuclear Reactors (Environmental Impact Assessment for
Decommissioning) Regulations 1999 (EIADR99) and the Town and Country Planning (Environmental Impact Assessment)
1999 Regulations (TCP(EIA) 99), Environmental Statements were compiled in which potential impacts and key mitigation
measures were identified for the three stages of decommissioning.
There have been no significant changes to the mitigation measures that were submitted in the Environmental Statement and
reported in the previous issue (October 2015) of the Environmental Management Plan.
The mitigation measures identified in both Environmental Statements are presented in the tables in normal script, the
mitigation measures identified in the ES under EIADR99 only are in italics and those mitigation measures identified in the
ES under the TCP (EIA) 99 only are underlined.
The following tables list the mitigation measures identified for each phase of the decommissioning project separately
(Tables 1 – 3).
Table 1: Care & Maintenance Preparations Phase Mitigation measures already identified (Condition 3a)
Topic Nature of impact Mitigation Measures Identified
Air Quality and Dust
Dust emissions during excavation, demolition and construction activities (including handling and storage of soil and material)
Minimising unnecessary handling of materials and drop heights
Carrying out the activities during a period of poor dispersion conditions (i.e. very low wind speeds) and minimizing activities in dry/windy weather conditions.
Enclosing containers during loading and transport
Using water sprays to maintain damp surfaces during dry weather
Seeding surfaces of completed mounds
Construction of wind fences around dust sources
Dust emissions during movement of vehicles
Sheeting of lorries containing materials and spoil export
Enclosing containers during loading and transport
Wheel washing of vehicles when leaving the site
Archaeology and Cultural Heritage
Impact on cultural heritage (decommissioning of buildings, structures and the technology housed within)
A Royal Commission on the Historic Monuments of England (RCHME) level 1 survey of the affected site buildings to be undertaken prior to decommissioning. The RCHME was merged with English Heritage in April 1999.
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Table 1 Continued: Care & Maintenance Preparations Phase Mitigation measures already identified (Condition 3a) - continued
Topic Nature of impact Mitigation Measures Proposed
Ecology Loss of habitat (grassland) as a result of off-site storage of materials and equipment. Loss of foraging habitat for badgers, bats, birds and amphibians
Grassland will be reinstated after removal of spoil mound
Landscape planting will provide some replacement habitat (See Landscape and Visual)
Retained areas of valuable habitat will be protected with appropriate fencing
Disturbance to nesting birds as a result of clearance of vegetation (or demolition of buildings)
All clearance of vegetation and demolition of buildings, likely to be of value to nesting birds, to be undertaken outside the bird breeding season
Disturbance to birds from traffic and site noise
Appropriate fencing and other barriers will be erected to protect particular sensitive areas
Close boarded fencing around the construction site will be erected to mitigate noise and human disturbance
Noisy operations will be programmed sensitively
Increased road mortality for badgers, nesting birds and great crested newts
Implement speed limits
Dust deposition on coastal grassland, species rich grassland and scrub along Branland Copse
See mitigation measures proposed under ‘Air Quality and Dust’ topic in this table
Pollution/sedimentation of freshwater habitats for water voles and otters
See mitigation measures proposed under ‘Surface Waters’ topic in this table
Habitat creation A new pond will be created to provide additional breeding habitat for amphibians
Geology, Hydrogeology and Soils
Changes to groundwater quality through disturbance of contaminated soils from excavation of subsurface structures and/or surfaces
A programme of sampling and testing of soils during excavation will be agreed with the EA and HSE
Contract documents will seek to ensure that groundwater ingress to excavation and demolition areas will be controlled to minimise the volume of water subsequently requiring management
Management of contaminated soils to avoid leaching into previously clean soils and groundwater
The containment and off-site disposal of contaminated soils
Groundwater infiltration and drainage from areas used for temporary storage of demolition waste materials or soils would be controlled to minimise the risk of leaching of contaminants and generation of contaminated or high pH water. Detailed proposals will be made for the collection and disposal of any potentially radiologically contaminated groundwater
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Table 1 Continued: Care & Maintenance Preparations Phase Mitigation measures already identified (Condition 3a) - continued
Topic Nature of impact Mitigation Measures Proposed
Changes to groundwater quality through spills and leaks
Utilisation of appropriate measures recommended in EA Pollution Prevention Guidance Notes (PPG2 and PPG6)
A spill response plan will be produced to deal with significant spillages to reduce the potential for environmental impact
Appropriate siting, bunding and drainage of fuel and oil tanks and concrete mixing facilities
Installation of adequately sized and designed oil separation units
Provision of sand, dispersants and oil booms
Changes to groundwater level
Inert backfill (e.g. uncontaminated demolition rubble from the site) would be placed and compacted within underground structures and artificial drainage points created to prevent build-up of groundwater levels
Landscape and Visual
Visual impact from the site wide demolition activities and construction of Intermediate Storage Facility (ISF) and Intermediate Level Waste (ILW) store etc.
Planting scheme will be implemented: This will include additional off-site woodland planting to the
south of the car park and visitor centre. It will soften views of Hinkley Point A site from viewpoints to the south west.
Additional on-site tree planting at the southern part of the site, but outside of the inner security barrier, situated to the north and to the north east of the reactor buildings.
Extensions to the existing Branland Copse mitigating views from the coastal path.
Provide an area of open tree planting and indigenous grassland within the site, but outside of the inner security barrier, situated to the north and to the north east of the reactor buildings.
Provide a long-term visual softening in long views from the access road and mitigate the views of the ISF from the south and the south east by creating a wide hedgerow with trees.
Visual extension of Branland Copse North by creating a 4m hedgerow along the north part of the western boundary.
Mitigate the loss of grassland habitat resulting from the ISF development (i.e. soil stockpile area). This adverse impact will be mitigated by restoring the grassland habitat. The area will be seeded with low-density indigenous grass mix, sown directly onto soil. Fertilisers would not be used.
Design, siting of buildings and choice of colour of cladding materials have been developed with the aim of reducing the visual impact.
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Table 1 Continued: Care & Maintenance Preparations Phase Mitigation measures already identified (Condition 3a) - continued
Topic Nature of impact Mitigation Measures Proposed
Noise and Vibration
Noise from site activities (demolition, construction of ISF, etc.)
All construction activities to be undertaken in accordance with good practice as described by British Standard 5228: 2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites
Main noise generating activities restricted to daytime hours (between 08:00 and 17:00), work outside these hours will be agreed with local authority
Mitigation by distance and screening will be maximized where possible Use of concrete crushers rather than pneumatic hammers Use of equipment fitted with effective silencers/insulation Minimising unnecessary revving of engines, turning off machines
when not required and routine maintenance of equipment Appointment of site supervisors to whom complaints/queries about
construction activity can be directed – any complaints to be investigated and action taken where appropriate
If piling is considered to be necessary, jacked or bored piling
techniques to be used in preference to driven piling
Noise related to transport
Maximum axle weights for transportation of plant materials and waste could be imposed by contract
Socio-economic Reduction in number of site personnel
Phasing of employment reductions
Maximising opportunities for employment continuity or redeployment
within the Company for site personnel Maximising take-up of the voluntary severance scheme
Change in employment level in local economy; change in level of local expenditure
Use of locally based contractors
Maximise the opportunities for locally-based businesses to secure involvement as contractors, sub-contractors and suppliers
Surface Waters Changes to surface water quality through uncontrolled discharges arising from excavations into contaminated soils
Contract documents will seek to ensure that surface water ingress to excavation and demolition areas will be controlled to minimize the volume of water subsequently requiring treatment
Any contaminated soil will be isolated and appropriately disposed of Drainage from excavation areas will be collected and managed
2BS5228 : 1997 has been superseded by BS5228 : 2009 parts 1 and 2.
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Table 1 Continued: Care & Maintenance Preparations Phase Mitigation measures already identified (Condition 3a) - continued
Topic Nature of impact Mitigation Measures Proposed
Surface Waters (Continued)
Changes to surface water quality through uncontrolled discharges of sediments and/or turbid water into surface drains and surface water courses
Follow EA Pollution Prevention Guidelines (PPG 1 and PPG 5) Follow EA’s “Is your site right?” checklist
Minimise stockpiling of loose materials
Seeding of the soil stockpile to reduce wash-off of suspended solids
Erosion protection using geotextile materials considered when stockpiling materials over long periods
Minimising movement of soil during wet weather
Cleaning of roadways, including use or recirculating wheel washers and road sweepers
Silt traps, balancing ponds and approximately sized grills on drains
Changes to surface water quality through uncontrolled discharges of contaminated water through spills and leaks of non-radioactive material (e.g. concrete, cement, fuels, oils or other chemicals)
Follow EA Pollution Prevention Guidelines (PPG 2 and PPG 21)
Appropriate siting, bunding and drainage of fuel/oil tanks and concrete mixing facilities
Handling protocols for washing out of concrete mixing plant and refueling
Installation of adequately sized and designed oil separation units
A Spill Response Plan will be produced to deal with spillage and reduce the potential for oils to enter surface waters
Provision of sand, dispersants and oil booms to control spillages
Traffic and Transport
Mud on public highways
Wheel washing of HGVs is proposed to prevent mud being carried onto local roads from the site
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Table 2: Care & Maintenance Phase Mitigation measures already identified (Condition 3a)
Topic Nature of impact Mitigation Measures Proposed
Ecology Disturbance to birds from traffic noise during removal of ILW
Removal operations will be programmed sensitively
Increased road mortality for great crested newts during removal of ILW
The presence or otherwise of great crested newts could be monitored as part of site management during C&M phase
A detailed mitigation plan will be developed
Geology, Hydrogeology and Soils
Changes to groundwater quality through disturbance of contaminated soils from excavation of subsurface structures and/or services
A programme of sampling and testing of soils during excavation will be agreed with the EA and the HSE (now the ONR)
Management of contaminated soils to avoid leaching into previously clean soils and groundwater
Landscape and Visual
Visual impact from the constructed ISF
The planting management regime (e.g. replacing of trees and scrubs, thinning) would be agreed with the local planning authority, as relevant and appropriate
Surface Water Avoidance of localized flooding
Drainage facilities in place during and after C&M period to avoid localised flooding. Small land drains may need to be installed
Improvements to flood defences made as necessary to ensure continued protection of site until final clearance
Table 3: Final Site Clearance Phase Mitigation measures already identified (Condition 3a)
Topic Nature of impact Mitigation Measures Proposed
All topic areas It is predicted that the impact may be as those identified in Table 1
Mitigation measures proposed for this section are identical to those specified in Table 1
4.2 Future mitigation measures (Condition 3b and 3c)
Work activities beyond final site clearance phase have not yet been identified. As a result a list of mitigation measures
required during any future phases cannot yet be identified.
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5. Implementation of the Environmental Management Plan
It is a requirement of the conditions attached to the consent
(Appendix A), to implement the mitigation measures and
describe their effectiveness. This chapter lists the
measures (identified in Table 1) which have been
implemented, explains how the site measures their
effectiveness in reducing environmental impacts and
describes their use in some relevant projects from 2016/17.
Process for Implementation of Mitigation Measures
Hinkley A site procedures ensure that decommissioning
activities are carried out in accordance with the mitigation
measures set out in this plan. All decommissioning projects
and modifications to plant are assessed during the proposal
stage in accordance with robust company management
control procedures. A template of questions (forming part of
the Decommissioning Project Approval Form (DPAF)) is used
to determine whether further environmental assessment and
mitigation is required (Appendix B).
In addition, there are a number of other tools to ensure that all
environmental impacts are minimised. The site has an
Integrated Management System which covers the
requirements of ISO 9001 (Quality Assurance), ISO 14001
(Environmental Management Systems) and OHSAS 18001
(Occupational Health and Safety Management System).
Hinkley A also undertakes Best Available Techniques (BAT)
optioneering studies for those projects where it is deemed
that there is potential for significant radioactive and non-
radioactive discharges and disposals from the site, e.g. site
waste management, decommissioning or restoration projects
and where it is required to demonstrate that these impacts
are minimised through evaluation by a clear, systematic and
transparent process.
Seaweed sampling at HPA
Processes for Determining Effectiveness of Mitigation Measures
The site aims to continually monitor the effectiveness of
mitigation measures over time and where necessary review
these in order to ensure the success of reducing significant
environmental impacts. A key part of this process is the
close interaction between the Project Teams and the
Environment Team, ensuring that mitigation measures are
considered, applied and, where relevant, reviewed
throughout the lifespan of the project. The effectiveness of
the mitigations is monitored in a variety of ways as described
below.
1) Environmental Performance Monitoring
Environmental performance monitoring (e.g. dust, noise,
groundwater monitoring) is performed using specialist
equipment. This allows assessment of environmental
impacts post-mitigation in addition to being of use for
determining baseline conditions. The main use of post-
mitigation environmental monitoring will be for larger
projects, such as the demolition of buildings or movement of
large quantities of spoil. The requirement for this method of
measuring effectiveness is determined on an individual project
basis as appropriate.
2) Visual Evidence
Site photographs taken before the start of the project
provide a good visual indication of the surrounding area
and help to identify potential environmental receptors in the
vicinity (e.g. surface drains) and hence highlight mitigation
measures that need to be implemented. Visual inspections
and photographs can also provide an indication on
effectiveness of mitigation measures.
3) Review of Regulatory Action, Complaints and Internal Event Reporting
Regulatory actions, complaints and internal events
including near misses are reported and investigated.
Such investigations may provide recommendations for
improvements where mitigation measures have not been
effective or where further mitigations are required.
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Examples of Work Completed Requiring Mitigation Measures
Limited decommissioning work has been undertaken during
the period. This resulted in few potential environmental
impacts; therefore many of the mitigation measures
described in the previous section have not been required.
The Ponds Project has now completed the Hinkley scope
of work and the majority of the team has moved on to
Oldbury. Hinkley Ponds have been drained. Work began
in 2005 and following a pause in project work from 2010-
2012, physical decommissioning work recommenced in
2013. Approximately 10m3 of highly active sludge and over
5000m3 of water has been removed, significantly reducing
the radioactive hazard inventory at the site.
The photos below demonstrate the level of remediation that
has been undertaken in the fuel ponds; what was once one
of the highest hazard areas on site can now be accessed
without respiratory protection. Where the personnel are
stood in the picture below once housed spent reactor fuel
under six metres of water.
Air Quality and Dust
Activities inside and outside buildings including the pond
wall shaving were subject to dust suppression and
filtration removing the risk of dust emissions to the
environment. Area of Potential Concern (APC) 9 has
dedicated misting devices to suppress the generation of
dust during drilling and excavation activities.
Ecology
A phase 1 habitat survey and targeted protected species
survey was undertaken in May 2010. The survey
concluded that the site is a potential nesting site for a
number of bird species. Ecology inspections are
undertaken prior to any building demolition and expert
advice sought as necessary.
Geology, Hydrogeology and Soils
Borehole sampling was undertaken on the Hinkley A site to
determine the extent of legacy oil ground contamination
associated with Area of Potential Concern (APC) 9; a
contract was, consequently, awarded to carry out
remediation. The work to remediate was completed with key
functional requirements confirmed in November 2016
.
APC 9 Ground Remediation at HPA
The following mitigations have been employed on site during
routine works:
Sampling and testing of all soil excavated to
determine the appropriate disposal route/re-use
Polythene sheeting laid down beneath the
excavated soil to prevent leaching/washing of
contamination to ground or drains
Polythene sheeting available to cover excavation
material in the event of heavy rainfall or wind to
prevent leaching/dispersion
Briefing of all site engineers involved in any site
excavation to be aware of the potential for
contamination and instructed to contact the
relevant environmental/waste engineer should any
obvious contamination be found e.g. presence of
hydrocarbons etc.
Provision of spill kits in the vicinity of the work
Part of the company procedure for identifying and
implementing measures to prevent potentially
contaminated soils leaching into ground or surface water is
shown in Appendix D.
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Landscape and Visual
Planting proposals outlined in Table 1 are to be
implemented following completion of work.
An area has been cleared and a concrete slab prepared
for the construction of the Interim Storage Facility and
Encapsulation Plant. Construction of the ISF is currently in
progress with construction of the encapsulation plant to
follow.
Noise and Vibration
All construction activities on site are subject to
management procedures which require implementation of
relevant good practice standards and procedures. All
noise generating activities are normally restricted to
between the hours of 08:00 and 17:00.
Any work which is likely to cause significant noise is
managed to ensure that no nuisance is caused and to
ensure no detriment to sensitive environments. No reports
have been received relating to excessive noise for
2016/17.
Socio-Economic
The total workforce (staff, agency and contractors) on site
has reduced in recent years but will flex during to reflect
the current decommissioning status; ultimately the
reduction will continue until C&M entry. The site aims to
mitigate the impacts of reduction in site personnel through
staff redeployment within the company and the voluntary
severance scheme. Change in employment levels in the
local economy is mitigated by maximising the opportunities
for locally-based businesses and through employment of
locally based contractors.
Surface Waters
Removal of redundant, legacy wastes continues on the site
with conventional water treatment plant tanks drained,
remedially cleaned and deplanted. This has had the effect
of removing a significant volume of legacy caustic waste
and has mitigated the significant environmental risk
associated with legacy caustic liquids being stored
indefinitely in redundant tanks.
Site management procedures ensure well managed oil and
chemical storage areas and routine inspection and
maintenance of tanks and oil interceptors.
Traffic and Transport
Transport levels in the local area will have increased due to
the development of the Hinkley Point C site and the
requirement for changes to the road layout immediately to
the south of the site. Construction of the Cannington
bypass is intended to help to alleviate traffic in the village.
Traffic concerns are raised at the SSG meetings; some
complaints relating to speeding vehicles have been
received through this forum. Coincident with EdF, the site
management team has taken action to remind Hinkley
Point A staff and contractors of the expectation that, where
practicable, the bypass should be used. In addition, a
reminder that adherence to speed limits is both an
expectation from a stakeholder management perspective
and legal obligation has been issued.
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6. Changes to the Environmental Management Plan
There are no significant changes to the mitigation measures that were submitted in the Environmental Statement and reported in previous issues of the Environmental Management Plan. Hinkley A site will notify the ONR of any significant change to a mitigation measure no less than 30 days before the change is made, or within such shorter time as the ONR may agree.
7. Distribution of the Environmental Management Plan
Any queries relating to the decommissioning activities at Hinkley Point A or requests for copies of this EMP should
be addressed to:
The Closure Director
Hinkley Point A Site
Nr Bridgwater
Somerset
TA5 1YA
In addition to the submission of this EMP to the ONR, Magnox Ltd will make the document publicly available via the
Magnox Website and will provide copies to the:
Hinkley Point A Site Stakeholder Group
This EMP may be viewed at the following locations:
Burnham and Highbridge Council Hinkley Point A Site Stakeholder Group
Nether Stowey Library
www.magnoxsites.com/publications
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8. Definitions
AONB Area of Outstanding Natural Beauty
APC Area of Potential Concern BAP Biodiversity Action Plan BAT Best Available Techniques DPAF Decommissioning Project Approval Form EA Environment Agency EIADR99 Nuclear Reactors (Environmental Impact
Assessment for Decommissioning) Regulations 1999
EMP Environmental Management Plan
HSE Health and Safety Executive ILW Intermediate Level Waste ISF Interim Storage Facility
ISO 9001 Accreditation system for Quality Assurance
ISO 14001 Accreditation system for Environmental
Management Systems
NAPL Non Aqueous Phase Liquid NNR National Nature Reserve
OHSAS Accreditation system for Occupational Health 18001 and Safety Management Systems
ONR Office of Nuclear Regulation
SAC Special Area of Conservation
SLA Special Landscape Areas
SPA Special Protection Area
SSG Site Stakeholder Group
SSSI Site of Special Scientific Interest
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Appendix A Consent Conditions
NUCLEAR REACTORS (ENVIRONMENTAL IMPACT ASSESSMENT FOR DECOMMISSIONING) REGULATIONS 1999
CONDITIONS
Attached under regulation 8(4) to Decommissioning Project Consent No. 1 granted under regulation 4(b)
HINKLEY POINT A POWER STATION
Condition 1
The project1 shall commence before the expiration of 5 years from the date of this Consent.
Condition 2
(1) The licensee is required to prepare and implement an environmental management plan to cover mitigation measures to prevent, reduce and where possible offset any significant adverse effects on the environment.
(2) The project shall not be carried out except in accordance with the environmental management plan.
Condition 3
Within 90 days of the date of this Consent, with reference to the Environmental Statement provided under regulation 5(1) and further information provided under regulation 10(9), the environmental management plan shall:
a. list the mitigation measures that are already identified;
b. list the options to implement work activities where mitigation measures may be required but where selection of an option will only be possible in the future;
c. list the work activities where mitigation measures may be required but where assessments to identify mitigation measures will only be possible in the future.
Condition 4
Subsequent to condition 3, the environmental management plan shall:
a. with reference to condition 3b, identify the mitigation measures for options that have been selected, giving reasons for their selection;
b. with reference to condition 3c, identify the mitigation measures from assessments carried out, giving reasons for their selection;
c. describe the effectiveness of the mitigation measures over time;
d. describe significant changes to the mitigation measures in light of experience, giving reasons for such changes.
1 Project as defined in regulation 2
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Condition 5
The licensee is required to:
a. provide the environmental management plan to the Health and Safety Executive within 90 days of the date of this Consent and every year thereafter, or within such longer time as the Executive may agree;
b.make the environmental management plan available to the public within 30 days of the plan being sent to the Health and Safety Executive, or within such longer time as the Executive may agree; the plan may replace earlier versions.
Condition 6
The licensee is required to provide notice to the Health and Safety Executive of any significant changes to a mitigation measure to prevent, reduce and where possible offset any major adverse effects on the environment no less than 30 days before the change is made, or within such shorter time as the Executive may agree.
Dated: July 2003
For and behalf of the
Health and Safety Executive
Signed
M W Weightman
A person authorized to act in that behalf
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Appendix B
Minimising Environmental Impacts — Decommissioning Proposal Approval
Form
PART 5 – ENVIRONMENTAL SAFETY ASSESSMENT Both 5.1 and 5.2 are to be categorised individually before an overall environmental category is assigned in 5.3.
5.2 EIADR 99 ENVIRONMENTAL IMPACT AND REGULATORY COMPLIANCE The following checklist must be completed by an Environmental SQEP/S*. The assessment is for compliance with the decommissioning consent and other relevant aspects of compliance with the EIADR99 Regulations, non-radiological permits/consents, other relevant legislation and environmental issues. *Generally Environmental SQEP/s on site have competency to assess all aspects of 5.2, where this is not the case, the site must ensure that appropriate assessment is made.
PARAMETER CONSIDER POTENTIAL FOR: NO YES
5.2.1 Decommissioning Baseline
Does this proposed modification represent a change from the Decommissioning Project baseline as described in the Environmental Impact Assessment Baseline document (in particular, is it sufficient to trigger Regulation 13 determination)? If ‘YES’, it is considered to be a change - complete the relevant Assessment Forms in accordance with S-159.
5.2.2 Management Does the proposal challenge compliance with the EIADR Regulations including adequacy of mitigation measures proposed?
5.2.3 Discharges & Waste
Could the proposal, if inadequately conceived or executed, lead to a breach of an existing Environmental Permit, or other environmental license/regulatory requirement (e.g. wildlife management license, PCB registration, greenhouse gas trading permit, marine consent, waste management exemption)? (For Scottish sites, a breach of a Controlled Activities Regulations Discharge Consent, Pollution Prevention Control Permit, Waste Management / Exemption?)
5.2.4 Discharges & Waste
Is a change to an existing Environmental Permit or new Environmental Permit required for this proposal? (For Scottish sites, a change to existing/or a new Controlled Activities Regulations Discharge Consent, IPC authorisation, PPC Permit, Waste Management / Exemption?)
5.2.5 Environmental Impacts
Could the proposal, if inadequately conceived or executed, lead to a an unacceptable environmental impact (e.g. inadequate storage of oils and chemicals leading to on or off-site spill, disturbing known or suspect contaminated ground)?. If so, appropriate controls/ mitigation must be specified
5.2.6 If all answers are ‘NO’ then the proposal is Category E3. If ‘YES’ is answered to any questions above, then assess the environmental impacts and provide further information below.
5.2.7 CONTROL MEASURES AND COMMENTS Describe the control measures that will be used to ensure that environmental risks will be acceptable.
5.2.8 Potential Environmental Category with respect to EIADR 99 Compliance and all other environmental aspects:
E1 E2 E3
Name: Environment SQEP
Signature: Date:
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Appendix B – Continued Minimising Environmental Impacts — Decommissioning Proposal Approval Form
PART 5 – ENVIRONMENTAL SAFETY ASSESSMENT
Both 5.1 and 5.2 are to be categorised individually before an overall environmental category is assigned below.
5.3 OVERALL ENVIRONMENTAL ASSESSMENT
To be completed by the NRE, with signatures from Environmental SQEP and EHSS&Q Manager as appropriate.
5.3.1 ENVIRONMENTAL JUSTIFICATION / MITIGATION
5.3.2 OVERALL ENVIRONMENTAL CATEGORY The environmental category is determined by reviewing the adequacy of the environmental hazard identification and assessment carried out and consider whether any other relevant aspects of the category definitions given in MCP-099 Appendix 1 are relevant. Select the relevant box below.
Environmental control and mitigation measures required have been identified above and will be incorporated in the design or working methods. Any further Environmental Justifications (e.g. BAT / BPM) should be attached.
RECOMMENDED ENVIRONMENTAL CATEGORY:
E1 E2 E3 Name: Environment SQEP
Signature: Date:
For category E1 modifications, two additional signatures are required:
1) Confirm awareness of the modification proposal. Name:
EHSS&Q Manager Signature: Date:
2) Confirm that the modification proposal has been reviewed by Head of Profession – Environment and that comments / recommendations have been addressed. Name:
NRE Signature: Date:
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Appendix C
Stakeholder Engagement
Whilst decommissioning represents a new phase in the lifecycle of the site, Magnox Ltd remains
committed to engaging with stakeholders at all phases in the process.
The Site Stakeholder Group (SSG) is an open public meeting. It meets three times a year and is chaired by an
independent chairman. Both the A and B sites are represented and an update is provided on site works. The
chair regularly meets with the Hinkley A Site Closure Director and is also in regular contact with the Nuclear
Decommissioning Authority (NDA).
The role of the Nuclear Decommissioning Authority (NDA)
The Energy Act (2004, as Amended) requires that the NDA must prepare a strategy for carrying out its functions
and from time to time to review that strategy. This strategy must set out the steps that the NDA proposes to take
for:
giving appropriate publicity to its responsibilities and strategy;
explaining them both to persons having a particular interest in matters relating to the carrying out by the
NDA of its functions and to the general public;
ensuring that the NDA is kept informed at all times of the opinions about such matters of persons
having such a particular interest;
facilitating the communication by such persons of their opinions to the NDA.
The NDA is also required to give encouragement and other support to activities that benefit the social or
economic life of communities living near those sites for which it has responsibilities, including Hinkley A.
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Appendix D
Format of Land Quality Assessment Form
QUESTIONS TO BE ADDRESSED WHEN APPROVING PROPOSALS FOR WORK ON SITE
In considering proposals for work on a site (through Modifications approval or method statement approval processes),
a number of questions relevant to land quality must be answered. These are set out below in a pro-forma, the layout
of which may be adapted for use within an existing procedure.
1. Does the proposed work have any potential for mobilisation of existing contaminated ground or groundwater?
1a. Will the proposed work involve ‘breaking ground’ or otherwise have the potential to affect the sub-surface?
Such work may involve excavations, advancing of boreholes or piles, changes in ground cover, changes to surface water drainage, groundwater abstraction, ground de-watering.
Yes/No
If the answer to 1a is yes:
1b. Is there any existing known or suspected contaminated land that could be affected significantly by the proposed work?
The answer to this question shall be based on consultation of the Land Quality Map and related Land Quality Register, noting that indirect effects such as modification of groundwater pathways can mean that work in one area may affect contamination present in another area.
Yes/No
If the answer to 1b is yes:
Give details of the mitigation measures proposed to eliminate / mitigate any potential impacts.
Proposed mitigation measures:
Was specialist advice sought in answering Question 1?
Yes/No
Give details of who was consulted. Give name and role, e.g. Intelligent Customer (land contamination) or Environmental SQEP:
2. Does the proposed work have any potential to result in exposure of those undertaking the work to contaminants at levels that should be taken into account in the Method Statements and Risk assessments for the work?
Yes/No
This question should be answered with reference to the Land Quality File. If yes, detail the measures to be put in place to provide
adequate protection of the workers.
Proposed mitigation measures:
Was specialist advice sought in answering Question 2?
Yes/No
Give details of who was consulted. Give name and role, e.g. COSHH Assessor / Accredited Health Physicist:
Assessment prepared by (give name & role and date):
Assessment approved by (give name & role and date):
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Appendix E
Principles for a Travel Plan
Objective
All decommissioning operations involving transport will be managed so as to minimise the environmental effects of
these operations, as far as is reasonably practicable. The principles for achieving this are defined below.
Transport Management Principles
• The numbers of individual transport movements will be minimised as far as is reasonably practicable.
• Employees and contractors will be encouraged to use video and teleconferencing facilities as much as possible
rather than travelling to other sites for meetings.
• Employees and contractors will be encouraged to share transport (or use public transport) when travelling to and
from the Hinkley Point A Site.
• Employees and contractors will be given awareness training on the principles of eco driving to minimise the
environmental effects of vehicle emissions.
• Magnox Ltd and its contractors will be required to maintain their vehicles in a good standard of condition.
• When appropriate, vehicles leaving the site will be subject to wheel wash and inspection to ensure that earth and
other material is not unduly dispersed.
• On site roads will be swept as necessary to minimise the spread of material off site and/or into drains or
watercourses.
• Signage will be provided at site exits to reinforce the contract requirements on vehicle drivers.
• Where practicable, transport distances will be minimised by the use of local disposal sites, recycling companies,
etc.
• Most HGV transport movements will be undertaken during normal working hours.
• HGVs will be required to exit the site through the Hinkley Point A main gate and, where appropriate, to follow
preferred routes to and from the strategic road network.
• In the event of the need for an abnormal load to be transported, a specific plan for this movement will be
developed.